Manufacture requires a distinct marketable product; fabrication of structural steel sections for a specific shed was not excisable.

Fabrication of purlins, trusses, rafters and bracings from steel channels, angles, plates and rounds did not amount to manufacture for excise purposes because the items were only measured, cut, drilled and sized for a specific structure, retained their identity as structural steel sections, and were not shown to be marketable as distinct commercial goods. Mere labour, job work, or use of drawings was insufficient to create a commercially distinct excisable commodity under Section 2(f). The excise demand was therefore unsustainable and no duty was payable on the fabricated structural components.

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Issues: Whether fabrication of purlins, trusses, rafters and bracings from steel channels, angles, plates and rounds amounted to manufacture and rendered the products dutiable under the central excise tariff.

Analysis: The fabricated items were made by measuring, cutting, drilling and sizing steel sections supplied for a specific shed or structure. The resulting articles retained their identity as steel sections fitted to predetermined positions in the structure and were not shown to be marketable as independent commercial goods. Mere labour, job work, or the use of detailed drawings did not, by itself, establish manufacture. On the facts, the process did not bring into existence a commercially distinct excisable commodity within the meaning of Section 2(f).

Conclusion: The fabrication did not amount to manufacture, and no duty was leviable on the goods demanded in the two orders.

Final Conclusion: The excise demands were unsustainable and the appellants were held not liable to pay duty on the fabricated structural components.

Ratio Decidendi: Mere cutting, drilling and sizing of steel sections for use in a specific structure, without emergence of a distinct and marketable commercial product, does not constitute manufacture for excise purposes.

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